Subject: File No. S7-07-13
From: Rachel LaBruyere

I strongly support the SEC’s proposal requiring companies to disclose the CEO-to-median worker pay ratio, as required by the Dodd-Frank Wall Street Reform and Consumer Protection Act.

Pay ratio disclosure will help investors evaluate CEO pay levels when voting on executive compensation matters. The ratio of CEO-to-worker pay is a valuable metric for investors because it places CEO pay levels into a broader perspective. For example, investors may use pay ratios as a factor when casting say-on-pay votes.

Pay ratio disclosure will also help investors better understand their company’s overall compensation for all employees. High CEO-to-worker pay ratios can have a negative impact on employee morale and productivity. Disclosure of pay ratios will help the capital markets better allocate capital to those companies that invest in their workforces.